20240919Staff 1-7 to PAC.pdf

RECEIVED
2024 September 19
IDAHO PUBLIC
MICHAEL DUVAL UTILITIES COMMISSION
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11714
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
FOR APPROVAL OF THE ASSET ) CASE NO. PAC-E-24-11
TRANSFER AGREEMENT BETWEEN )
ROCKY MOUNTAIN POWER AND THE )
CITY OF IDAHO FALLS—HOLMES ) FIRST PRODUCTION
AVENUE ) REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attorney General, requests that Rocky Mountain Power, a division of
PacifiCorp ("Company")provide the following documents and information as soon as possible,
but no later than THURSDAY, OCTOBER 10, 2024.
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 SEPTEMBER 19, 2024

In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: Please explain how affected customers are being notified of the
proposed asset transfer.
REQUEST NO. 2: Please provide the workpapers, with all formulas intact and enabled,
including source documents,used to determine the value of the assets shown in Exhibit A
(Description and Value of Assets Serving Transferred Customers), including the Plant in Service,
Income Taxes, and Separation/Estimator Costs.
REQUEST NO. 3: Please provide a list of all assets included in the transaction by
description, year in service, installed valuation, and current book value.
REQUEST NO. 4: Please provide the accounting treatment and journal entries for the
following. Please include spreadsheets with formulas intact and enabled for the following:
a. The gain or loss on the sale of these assets;
b. The removal of these assets from the Company's books; and
c. Any other journal entries necessary to complete the transaction.
REQUEST NO. 5: Please provide copies of the 12 monthly invoices used for the
revenue component listed in Exhibit A.
REQUEST NO. 6: Please explain how the proposed transaction complies with Idaho
code § 61-328(3). This response should outline how the transaction is consistent with the public
interest and explain how the cost of-and rates for-supplying service will not be increased by
reason of such transaction. This response should also illustrate how"the applicant for such
acquisition or transfer has the bona fide intent and financial ability to operate and maintain said
property in the public service." Idaho Code § 61-328(3)(c).
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 19, 2024

REQUEST NO. 7: Please provide legible maps showing the locations(s) of facilities to
be transferred.
DATED at Boise, Idaho, this 19th day of September 2024.
Michael Duval
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\PAC-E-24-11 PR#l.docx
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 SEPTEMBER 19, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF SEPTEMBER 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-
24-11, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK ALDER DATA REQUEST RESPONSE CENTER
JOE DALLAS E-MAIL ONLY:
ROCKY MOUNTAIN POWER datarequest(d),pacificorp.com
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: mark.alderkpacificorp.com
joseph.dallas(&,pacificorp.com
IDAHO FALLS CITY POWER
BEAR PRAIRIE
140 S CAPITAL AVENUE
BOX 50220
IDAHO FALLS ID 83405
E-MAIL: bprairie(kifpower.org
KERI HAWKER, SECRETARY
CERTIFICATE OF SERVICE